Download or read book Advance Tax Rulings and Principles of Law written by Carlo Romano (juriste).) and published by IBFD. This book was released on 2002 with total page 579 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comprehensive study on the advance tax ruling. The main procedural and substantive elements of current tax rulings systems worldwide are investigated, and the legal principles underlying advance tax rulings procedures in the United States, the Netherlands and Italy are identified. In the final chapters, an overview of the status quo of advance tax rulings systems in the EU Member States is followed by a discussion concerning the harmonization of advance rulings systems in the European Union.
Download or read book Introducing an Advance Tax Ruling ATR Regime written by Mr.Christophe J Waerzeggers and published by International Monetary Fund. This book was released on 2016-05-31 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
Download or read book Taxing German Dutch Cross Border Activities written by Bert Alink and published by Institut für Finanz- und Steuerrecht, Universität Osnabrück. This book was released on 2015-02-04 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cross-border economic activity is gaining more and more importance. This is especially true for the border region between Germany and the Netherlands. The GD Tax Centre was founded to research on the taxation of such activities in 2012. The GD Tax Centre brought together renowned scientists and a significant number of emerging young talents from both sides of the border over a period of three years. This anthology represents some of the research results of the GD Tax Centre. Further research results have been made public via events, presentations or academic publications and a variety of other ways. It consists of many different articles, which mainly discuss topics of cross-border business activities and compare the tax treatment in Germany and the Netherlands. An enormous part of this book focuses on the new German-Dutch tax treaty, which hopefully will enter into force in January 2016. Additionally some articles concern a more general or even a more specific research question. This project was kindly supported by: University of Osnabrück, Tilburg University, University of Münster, PwC, Hartmann & Kiwit, De Kok, Provincie Gelderland, Provincie Overijssel, Euregio, Niedersächsisches Ministerium für Wirtschaft, Arbeit und Verkehr, Ministerium für Wirtschaft, Energie, Bauen, Wohnen und Verkehr des Landes Nordrhein-Westfalen, Interreg Deutschland-Nederland, European Regional Development Fund.
Download or read book Legitimate expectations in Luxembourg tax law written by Fatima Chaouche and published by Éditions Larcier. This book was released on 2019-06-25 with total page 525 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the result of a 4-year research project conducted at the Faculty of Law of the University of Luxembourg. It explores the legal value and enforceability of tax circulars and tax rulings in Luxembourg domestic law in light of the principle of legitimate expectations and related principles. After studying the historical roots of both interpretative acts, this research questions the level of protection taxpayers enjoy when relying on circulars and tax rulings and contains a review of decades of administrative case-law to assess the judicial discourse on taxpayers’ rights to certainty. This book further investigates the case of circulars and tax rulings that contain interpretations of tax laws that are contrary to the law (contra legem) and builds upon the existing normative framework to introduce proposals addressing issues of uncertainty and inequality taxpayers are likely to suffer when relying on such interpretative acts. Prix Pierre Pescatore de la Faculté de Droit de Luxembourg (École doctorale de droit).
Download or read book Optimization of Organization And Legal Solutions Concerning Public Revenues And Expenditures in Public Interest written by Ewa Lotko and published by Wydawnictwo Temida 2. This book was released on 2018 with total page 794 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Download or read book International Tax Law written by Andrea Amatucci and published by Kluwer Law International B.V.. This book was released on 2012-07-01 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: With a century of solid theory behind it, tax law confronts a new reality: the weakening of the tenacious link between the sovereignty of states and taxation. Yet it is to the continuity of certain themes and principles inherent in the various national tax systems that tax law scholarship continues to look, even as it develops new principles designed to meet the expanding processes of internationalization. This completely updated collection of essays offers an expert comparative analysis, conducted by a sample of the best international tax law scholars, of the fundamental theory of tax law and of the prospects in the near future of tax legislative systems. The emphasis falls naturally on tax theory, jurisprudence, and legislative development in the Member States of the European Union (particularly in Italy, Germany, and Spain), where the process of tax harmonization has been under way for many years. The effect of these processes, via the relevant tax treaties, on the tax systems of Japan and the United States provides a secondary emphasis. Practitioners and academics in tax law will find in this book an invaluable understanding of the challenges that tax law theory strives to meet at this crucial moment in economic history. The essays present a full and reliable exposition of the current theoretical approaches adopted by the various schools of thought in the field, as well as of the main contributions of jurisprudence.
Download or read book Legal Remedies in European Tax Law written by Pasquale Pistone and published by IBFD. This book was released on 2009 with total page 573 pages. Available in PDF, EPUB and Kindle. Book excerpt: Until now the topic of legal remedies in European direct tax law has been significantly underexposed within the academic tax community. This book aims at filling this gap by providing the typical approaches to European tax law with a general vision on European law, and puts together theory and practice, but also includes contributions on selected relevant issues arising in the protection of taxpayers' rights.
Download or read book The principle of non discrimination in international and European tax law written by Niels Bammens and published by IBFD. This book was released on 2012 with total page 1151 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.
Download or read book Financial Integration written by Marga Peeters and published by Springer Science & Business Media. This book was released on 2013-09-21 with total page 230 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Arab upheaval and the world's biggest financial crisis after the Great Depression were almost simultaneous in their occurrence. The Mediterranean economies now face a dual challenge of a political and financial restructuring in the light of a shaky economic pedestal on which they stand. In light of this socio-political and economic shift in both inland and in world markets, this book offers a thorough analysis on problems, prospects and the way ahead for the financial integration of the South-Mediterranean region. Several perspectives on financial integration and policy recommendations are put forward from a leading group of researchers specializing on the Mediterranean region.
Download or read book Introducing an Advance Tax Ruling ATR Regime written by Mr.Christophe Waerzeggers and published by International Monetary Fund. This book was released on 2016-05-31 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
Download or read book Interpretation of Tax Treaties under International Law written by F. A. Engelen and published by IBFD. This book was released on 2004 with total page 615 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
Download or read book EC Law and the Sovereignty of the Member States in Direct Taxation written by Mathieu Isenbaert and published by IBFD. This book was released on 2010 with total page 925 pages. Available in PDF, EPUB and Kindle. Book excerpt: In order to develop a suitable framework for the analysis of the European Court of Justice (ECJ) case law, it is first analysed what significance, if any, the concept of 'sovereignty' has in the contemporary supranational environment of the European Union. All too often, tax scholars equate 'sovereignty' with the concepts of 'competence' or 'jurisdiction'. It will be established in this thesis that a much more specific and higher-level meaning is to be attributed to the 'sovereignty' concept, which goes beyond the strictly legal concepts of 'competence' or 'jurisdiction'. The cornerstone of this thesis, however, is an extensive analysis of the case law of the ECJ in direct tax matters, including a comparison with its non-tax case law. A new kind of methodology is used in discussing the cases: they are categorized according to whether a discrimination - or a restriction - based analysis was applied by the ECJ.
Download or read book International Taxation Handbook written by Colin Read and published by Elsevier. This book was released on 2007-04-13 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: Description and extensions of the capital income effective tax rate literature / M.M. Ruiz, F. Gérard, M. ; p. 11- 41.
Download or read book Procedural Rules in Tax Law in the Context of European Union and Domestic Law written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2010-10-29 with total page 752 pages. Available in PDF, EPUB and Kindle. Book excerpt: This timely work seeks to identify the differences between the domestic procedural rules and principles of an array of EU and non-EU countries and analyse them in the context of European Union law requirements. Specific attention is paid to the impact of State aid rules on procedural law in tax matters, on constitutional law requirements as well as tax treaty law issues. Since customs law is already harmonized in the form of the Community Customs Code, it serves as a starting point to examine the extent to which harmonized procedural law is possible. Harmonized procedural law is also discussed in the context of a possible future Common Consolidated Corporate Tax Base as well as an EU tax levied at the European Union level.
Download or read book Cross border Consumption Taxation of Digital Supplies written by Pernilla Rendahl and published by IBFD. This book was released on 2009 with total page 461 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study compares cross-border consumption taxation of digital supplies in business-to-consumer transactions from an international coordination perspective. Hence, the various classifications of digital supplies and the provisions for deciding the place of taxation are compared and examined to identify cases of double taxation and unintentional nontaxation or potential risks thereof. In addition, possible remedies for double taxation and unintentional non-taxation are discussed.
Download or read book Integration Approaches to Group Taxation in the European Internal Market written by Ioanna Mitroyanni and published by Kluwer Law International B.V.. This book was released on 2008-10-13 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: The creation of a group taxation framework to subject affiliated entities resident in more than one EC Member State to a single set of rules is an experiment without precedent. Group taxation normally deals with tax liability in the context of a single jurisdiction. There is no system of group taxation worldwide which embraces more than one fiscal jurisdiction under a single regulatory umbrella. This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse. Among the topics covered. The relevant jurisprudential and legislative framework of the European Internal Market; A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers; The policies for corporate taxation in integrated markets; Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability; Tests for entitlement to group membership; Tax base integration; - Territorial delineation of the group; and Formulary apportionment. In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.
